taxation question kingsgate have a 5 year tax holiday, with the...

taxation question kingsgate have a 5 year tax holiday, with the thia government. i do not know much about taxation, but i read somewhere that there is a double taxation agreement between australia and thialand - which means that if a company pays tax in thialand, then it is free of australian taxation - which means profits, in the hands of kingsgate, are tax free. does this then extend to the payment of dividends?????? anybody have any idea????